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Change 1
As published
31 Payments for surrender of expenditure credits
(1) In section 1042N of CTA 2009 (amounts surrendered to other group companies), after subsection (4) insert—
(5) Subsection (6) applies (in addition to subsection (3)) if—
(a) the qualifying company and the other group member have an agreement between them in relation to the surrendering of amounts of expenditure credit, and
(b) as a result of the agreement the other group member makes a payment to the qualifying company that does not exceed the total amount of expenditure credit surrendered to the other group member.
(6) The payment is not to be—
(a) taken into account in determining, for corporation tax purposes, the profits of the qualifying company or the other group member, or
(b) regarded for corporation tax purposes as a distribution.
(2) In section 1179CE of CTA 2009 (amounts surrendered to other group companies), after subsection (4) insert—
(5) Subsection (6) applies (in addition to subsection (3)) if—
(a) the qualifying company and the other group member have an agreement between them in relation to the surrendering of amounts of expenditure credit, and
(b) as a result of the agreement the other group member makes a payment to the qualifying company that does not exceed the total amount of expenditure credit surrendered to the other group member.
(6) The payment is not to be—
(a) taken into account in determining, for corporation tax purposes, the profits of the qualifying company or the other group member, or
(b) regarded for corporation tax purposes as a distribution.
(3) The amendments made by this section have effect in relation to payments made on or after 26 November 2025.
Your change, as a redline
31 Payments for surrender of expenditure credits
(1) In section 1042N of CTA 2009 (amounts surrendered to other group companies), after subsection (4) insert—
(5) Subsection (6) applies (in addition to subsection (3)) if—
(a) the qualifying company and the other group member have an agreement between them in relation to the surrendering of amounts of expenditure credit, and
(b) as a result of the agreement the other group member makes a payment to the qualifying company that does not exceed the total amount of expenditure credit surrendered to the other group member.
(6) The payment is not to be—
(a) taken into account in determining, for corporation tax purposes, the profits of the qualifying company or the other group member, or
(b) regarded for corporation tax purposes as a distribution.
(2) In section 1179CE of CTA 2009 (amounts surrendered to other group companies), after subsection (4) insert—
(5) Subsection (6) applies (in addition to subsection (3)) if—
(a) the qualifying company and the other group member have an agreement between them in relation to the surrendering of amounts of expenditure credit, and
(b) as a result of the agreement the other group member makes a payment to the qualifying company that does not exceed the total amount of expenditure credit surrendered to the other group member.
(6) The payment is not to be—
(a) taken into account in determining, for corporation tax purposes, the profits of the qualifying company or the other group member, or
(b) regarded for corporation tax purposes as a distribution.
(3) The amendments made by this section have effect in relation to payments made on or after 26 November 2025.
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